The estimation of the Group’s liquidity risk is carried out with the use of both measures defined by the supervisory authorities and internally, for which exposure limits were established.
The evolution of the Group’s liquidity position in short-term horizons (up to 3 months) is tested daily on the basis of two internally defined indicators: immediate liquidity and quarterly liquidity. Both such indicators measure the maximum borrowing requirement, which could arise on a particular day, taking into consideration the cash-flow projections for spot date and period of 3 months, respectively. Additionally, the liquid asset portfolio is calculated on the daily basis.
These figures are compared with the exposure limits in force and reported daily to the areas responsible for the management and control of the liquidity risk in the Group as well as presented in monthly and/or quarterly basis to the Bank’s Management Board and Supervisory Board.
During 2019, all internal liquidity indicators were well above minimum limits. The liquidity risk limits are revised at least once a year in order to take into account, inter alia, the change of the size of the consolidated own funds, current and expected balance sheet structure, historical limits’ consumption, as well as current market conditions and supervisory requirements. The current limits in place have been valid since 1st January 2019 and will be replaced by revised limits on 1st January 2020.
Current Liquidity indicators PLN million
31.12.2019 | ||||
Immediate liquidity ratio (m PLN)* | Quarterly liquidity ratio (m PLN)* | Liquid assets Portfolio (m PLN)** |
LCR (%) | |
Indicator | 18 795 | 18 795 | 22 795 | 171% |
Minimum limit | 957 | (1 596) | 12 000 | 100% |
31.12.2018 |
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Immediate liquidity ratio (m PLN)* | Quarterly liquidity ratio (m PLN)* | Liquid assets Portfolio (m PLN)** |
LCR (%) | |
Indicator | 20 228 | 20 228 | 22 836 | 212% |
Minimum limit | 934 | (2 336) | 10 000 | 100% |
** Liquid Assets Portfolio: The sum of cash, exposure to Central Bank (the surplus above the required obligatory reserve) and Polish Government debt securities, NBP-Bills and due from banks with maturity up to 1 month. The debt securities portfolio is reduced by NBP haircut for repo transactions and securities encumbered for non liquidity purposes.
The Group monitors liquidity on the basis of internal liquidity measures, taking into account in particular the impact of FX rates on the liquidity situation.
According to the Regulation of European Parliament and Council no 575/2013 on prudential requirements for credit institutions and investment firms (CRR), the Group is calculating the liquidity coverage requirement (LCR). The regulatory minimum of 100% for LCR valid in 2019 was complied by the Group (as of the end of December 2019 the LCR reached the level of 171%). The measure is calculated daily and has been reported on the monthly basis to NBP since March 2014. Internally, the LCR is estimated daily and reported to the areas responsible for the management and control of the liquidity risk in the Group. In 2019, the Group complied also with supervisory measures imposed by KNF Resolution 386/2008 as well as regulary calculated net stable funding requirement (NSFR). In each of the quarter, the NSFR was above planned supervisory minimum of 100% (supervisory minimum will be valid in June 2021).
Additionally the Group employs an internal structural liquidity analysis based on cumulative, behaviour liquidity gaps calculated on a real basis (i.e. assuming the probability of cash flow occurrence). The safe level adopted by the Group for the ratio of liquidity shortfall is established for each time bucket below 5 years.
In 2019 liquidity gaps were maintained at levels significantly above the safe limits. The results of cumulative, behaviour liquidity gaps (normal conditions) are presented in tables below.
31.12.2019 | ||||||
---|---|---|---|---|---|---|
Adjusted Liquidity Gap (PLN million) | up to 6M | 6M to 12M | 1Y to 2Y | 2Y to 3Y | 3Y to 5Y | Over 5Y |
Adjusted balance assets | 33 558 | 6 884 | 11 756 | 9 705 | 12 790 | 36 047 |
Adjusted balance liabilities | 11 067 | 4 415 | 8 205 | 6 494 | 9 393 | 63 202 |
Balance-Sheet Gap | 22 491 | 2 469 | 3 551 | 3 211 | 3 397 | (27 155) |
Cumulative Balance-Sheet Gap | 22 491 | 24 960 | 28 511 | 31 722 | 35 119 | 7 965 |
Adjusted off-balance assets | 216 | 249 | 80 | 37 | 32 | 4 |
Adjusted off-balance liabilities | (1 435) | (71) | (87) | (39) | (48) | (8) |
Off-Balance Sheet Gap | (1 219) | 178 | (7) | (2) | (15) | (4) |
Total Gap | 21 272 | 2 647 | 3 545 | 3 209 | 3 382 | (27 159) |
Total Cumulative Gap | 21 272 | 23 919 | 27 464 | 30 673 | 34 055 | 6 896 |
31.12.2018 | ||||||
---|---|---|---|---|---|---|
Adjusted Liquidity Gap (PLN million) | up to 6M | 6M to 12M | 1Y to 2Y | 2Y to 3Y | 3Y to 5Y | over 5Y |
Adjusted balance assets | 30 398 | 5 728 | 7 932 | 7 389 | 8 953 | 29 089 |
Adjusted balance liabilities | 10 423 | 3 001 | 6 122 | 4 417 | 6 671 | 54 803 |
Balance-Sheet Gap | 19 974 | 2 727 | 1 810 | 2 972 | 2 283 | (25 714) |
Cumulative Balance-Sheet Gap | 19 974 | 22 701 | 24 511 | 27 482 | 29 765 | 4 051 |
Adjusted off-balance assets | 77 | 64 | 410 | 53 | 33 | 4 |
Adjusted off-balance liabilities | (1 294) | (83) | (114) | (61) | (39) | (10) |
Off-Balance Sheet Gap | (1 217) | (20) | (296) | (9) | (6) | (6) |
Total Gap | 18 757 | 2 707 | 2 106 | 2 963 | 2 277 | (25 720) |
Total Cumulative Gap | 18 757 | 21 465 | 23 571 | 26 534 | 28 811 | 3 090 |
The Group has developed a liquidity risk management tool defining sensitivity analysis and stress scenarios (internal, external and combination of both). For the purpose of stress tests, liquidity gaps are calculated on a real basis assuming a conservative approach to the assessment of probability of cash flow occurrence among others taking into account a reduction of deposits, delays of loans repayment, deteriorated liquidity of the secondary securities market, the highest cost of funding – the assumption of the worst observed margins on deposits in the Bank, parallel shift of the yield curve and PLN depreciation.
Stress tests are performed at least quarterly, to determine the Group’s liquidity-risk profile, to ensure that the Group is in a position to fulfil its obligations in the event of a liquidity crisis and to update the liquidity contingency plan and management decisions. Additionally, stress test results are used for setting thresholds for early warning signals, which aim is to identify upcoming liquidity problems and to indicate to the Management Board the eventual necessity of launching Liquidity Contingency Plan.
The results of the stress test analysis demonstrated that the liquidity indicators will be maintained above the established limits.
The information regarding the liquidity risk management, including the utilization of the established limits for internal and supervisory measures, is reported monthly to the Capital, Assets and Liabilities Committee and quarterly to the Management Board and Supervisory Board.
The process of the Group’s planning and budgeting covers the preparation of the Liquidity Plan in order to make sure that the growth of business will be supported by an appropriate liquidity financing structure and supervisory requirements in terms of quantitative liquidity measures will be met.
The Group has also emergency procedures for situations of increased liquidity risk – the Liquidity Contingency Plan (contingency plan in case the Group’s financial liquidity deteriorates). The Liquidity Contingency Plan establishes the concepts, priorities, responsibilities and specific measures to be taken in the event of a liquidity crisis. The Liquidity Contingency Plan is revised at least once a year. In 2019 the Liquidity Contingency Plan was tested and revised in order to guarantee that it is operationally robust. The Plan also adapted revised warning thresholds for early warning indicators, taking into account scenarios and stress test results. The revised Plan was approved by the Supervisory Board in December 2019.